The Super Bowl of compliance: the attorney behind the big game

On Super Bowl Sunday, the game itself won’t be the only nerve-wracking test of game plans.

Behind the scenes is Tom Ajamie, founding partner of Ajamie LLP. For nearly two years—long before the competitive field would whittle down to the New England Patriots and Atlanta Falcons—he and his firm have taken on the role of counsel to the Houston Super Bowl Host Committee, providing a wide range of legal services for the multibillion-dollar event.

Ajamie is the point man for ensuring that all involved parties—from advertisers to sponsors to ticket vendors—remain compliant with federal, state, and local laws and regulations.

Ajamie, an internationally recognized trial lawyer, is also the co-author of the book “Financial Serial Killers: Inside the World of Wall Street Money Hustlers, Swindlers, and Con Men.”

Compliance Week spoke to Ajamie about his work with the National Football League and preparing for Super Bowl LI.

How did this unique opportunity present itself?

The Houston Super Bowl host committee is a corporate entity that was set up to run the event. Each city that hosts a Super Bowl will have some kind of corporate entity to run it. There are about 50-60 people in the headquarters here in Houston and they have been there for about three years planning for not just game day but the 10 days of events leading up to it.

The way I became involved was that the president and CEO of the host committee, two years ago, was at the Houston Grand Opera reading her program. She saw corporate sponsors like Exxon and Shell and this guy with the strange name Ajamie. She thought she recognized that name from somewhere, called her mother in Phoenix, and remembered that this was someone she went to grade school with a long time ago.

She did some research and interviewed me along with other firms. I then had to go through a whole selection process, of course. They ultimately decided to hire us.

The people in this multibillion-dollar world of sports entertainment want to make sure that your experience is good. It drives everything. That should drive law firms and be your credo: ensuring that every client has a good experience and everything else falls into place from that.

Were you prepared for how much work would be involved in the process once you dove into all the interconnected events?

I really wasn’t. I thought, like I imagine most people do, of the Super Bowl in the context of being this very prominent game day. It is the most watched television program in the entire U.S. and one of the most watched on the planet, after the World Cup.

I knew it was a big day, but I absolutely had no idea of the amount of work and planning that leads up to it. There are also 10 days of events that lead up to it, including nearly 130 private corporate parties, fan experiences, concerts, and charity events. With all these parties, we are expecting well over one million people in town during the days leading up to the big game itself. It is like a huge, high-end state fair that requires a tremendous amount of planning.

With such a wide range of advertisers, sponsors entertainers, vendors, charities, and NFL itself, what does “ensuring compliance” entail for the various parties?

What it really means is complying with the law, and that includes non-profit laws too. We are set up as a non-profit organization for this purpose. All the money that is raised goes back into events for the community.

Compliance really means complying with the law, complying with zoning ordinances, health and safety ordinances, and ensuring public security by working with the Department of Homeland Security and other organizations.

In Texas, we have an “open carry” law, which means you can carry a gun. We had to get special permission from the state attorney general and others so that we could actually prohibit guns from the closed perimeter zone. Compliance has a lot of facets in something of this magnitude.

There are also cyber-security issues that we have worked through. Because it is such a high-profile event, we are very concerned about cyber-security and the fact we could be hacked for any number of reasons.

Any event of this size, of course, attracts hackers and others who want to disrupt it for any number of reasons. I just returned from the Sundance film festival, for example, and its website was hacked. For a few hours, they could not produce tickets for the various films. What’s the purpose? There really isn’t one except that hackers like to cause disruption. So yes, there are cyber-security concerns discussed at a lot of levels, some I can talk about; others, obviously, I cannot.

One issue is the vulnerability of e-mail, which is on everyone’s mind these days. We are very careful about what sort of confidential information is conveyed via e-mail, versus through one-on-one conversations.

Risk and the Super Bowl

In a Compliance Week podcast, we dig deeper into how Tom Ajamie, founding partner of the law firm Ajamie LLP, approached risk assessment for the Super Bowl and the many events leading up to the big game in Houston on Feb. 5.

We also discuss the challenges associated with broadcasters at the event and, with thousands of volunteers and staffers, his approach to training.

What about intellectual property and licensing for both sponsors and brands falling under the NFL umbrella? Is that also a concern?

We haven’t experienced any problems yet, but it is still early. At various Super Bowls, for example, there have been forged tickets that look very close to real tickets. The NFL has a dedicated, full-time lawyer, not us, who only looks into trademark issues for all events. It is a challenge for the NFL every day, not just Super Bowl Sunday

Are there risk assessments you will rely on? How will you assess your efforts? Will there be particular metrics or reporting lines used?

In the area of risk management and security issues, for example, we create charts along with the NFL. We list the types of risks out there, from compliance risks to security risks and litigation risks. We chart them from “least likely” to “most likely,” then break them into categories. There are about 18 risk categories we are monitoring on a daily basis to assess whether we are on top of these various activities. We monitor them daily.

What challenges have you already faced?

There are issues of crowd flow, which I never thought of until I got into this business here. Throughout the week we are dealing with millions of people coming downtown for concerts and events. How do you move people in and out? How would you rapidly evacuate them? Do you have enough exit space? Can people get out of the events during an emergency in a way that no one gets hurt?

It is eye-opening to see everything that goes into the event and all the moving parts that people going to the game, or watching, will never think about. And, they will never need to think about them if we do our jobs correctly.

For example, think about every little vendor you or I might walk by and decide to get a hot dog. With hundreds and hundreds of them, just setting everything up is an incredibly complicated process in terms of proper permitting, health codes, contractual issues, and insurance issues. They all need to be covered by insurance and we need to make sure we have checked all those policies.

What lessons what have you learned that may help your practice? What lessons would you share with compliance officers?

The thing I really learned that I’m certainly going to implement in my law firm’s practice is the emphasis on making sure that everyone has a positive experience.

The people in this multibillion-dollar world of sports entertainment want to make sure that your experience is good. It drives everything. That should drive law firms and be your credo: ensuring that every client has a good experience and everything else falls into place from that.

A good experience means good communication, keeping them apprised of what’s involved, making sure they are getting good value for their money and that all work is top tier. How do we interface with our customers? Are they having as good an experience as they can have when they are going through something tough?

The same applies to a compliance officer. In compliance, you need to win the hearts and minds of your people. How do you do that? Make sure they have a good experience. Make sure you are interfacing with them and interacting effectively with them.

An e-mail addressing a compliance issue is not sufficient. Have you met personally? Have you had talks with people? Are their positive interactions and positive results?